ONLY THE SHADOW (SYSTEM) KNOWS Randi Wasik, MBA, Director of Administration and Finance, University of Washington

Find & Prepare Proposal Institutional Review & Submittal Sponsor Review & Award Award Negotiation Award Set-Up Award Administration & Compliance Award Closeout

Reasonable, Allowable, Allocable – the grant management holy grail Put the correct charges on the correct fund right from the start. Undue cost transfers are a compliance issue. Reconcile fund activity monthly. Process all corrections as quickly as possible. Communicate with PI or designee monthly to review past expenditures and future projections. Do projections / burn rate and include IDCs!

 Plan – they should serve both you and your faculty - transparency  Model so they can accomplish multiple goals  Be consistent  Do regularly  Get up and meet with your faculty to review and discuss  Have the faculty sign the reports  More than one set of eyes  Use electronic tools

Transfer of cost from one institutional account to another Cost transfers can occur between: o two sponsored accounts o from a non-sponsored account to a sponsored account, o from a sponsored account to a non-sponsored account, o between two non-sponsored accounts

Federal regulations require that the effort of all individuals compensated or contributing effort to a federal project is verified. Effort is percent of total time an individual spends on all work-related activities (research, teaching, patient care, administration, etc.) within their institution. Cannot exceed 100%. Not based on 40 hour work week. Effort reporting certifies to the sponsors that effort committed to a project was completed.

Institutions are responsible for programmatic, administrative and financial monitoring of all awards made to sub-recipients under sponsored projects. Institutions have an obligation to monitor the sub recipients activities throughout the life of the award. Responsibilities include - PI, Department and Institution.

 Equipment  IRB  IACUC  Invoicing and Accounts Receivable  Scheduled Payments  Use for future budgeting and forecasting  Plan, forecast and account

 Financial Reports: ◦ All expenditures posted? ◦ All expenditures appropriate?  Equipment reports ◦ Who owns the property now: Institution or Sponsor? ◦ What is its distribution? ◦ Is it still being used?

Releases (Normally for Contracts) Payment linked to timing or milestones/deliverables Deficit Balances (Overruns) oCannot be shifted to other awards oCannot be included in F&A cost pools Surpluses oCost Reimbursement Agreements – Returned to Sponsor oFixed Price Agreements (including Clinical Trials) – Retained by Institution

Anticipate the project will be audited. Manage the award correctly from the beginning. Audits often take place several years after the project is completed. Organized Files Documentation for expenses including explanations of why items were charged Appropriate Approvals Audit Trails

12 Conduct of Research Principle: Ensures validity of results & maximizes return on public investment. Conflict of Interest, Research Integrity, Data, Resource Sharing, Cyber Security, Public access to Publications, Conflict of Commitment Public Policy Principle: Meets national social, economic, & security interests. SEVIS/Visas, Export controls Race, Gender, & Handicap Equality & Education, Lobbying, Debarment, Drug Use, USA Patriot Act Protections/Safeguards Principle: Provides for welfare of researchers, subjects, & environment. Human Subjects, Animal Welfare, HIPAA, Select Agents, Radiation, Environmental Health & Safety, Hazardous Materials, Radiation, Recombinant DNA, Lab safety Cost Policy and Financial Management Principle: Ensures fair and reasonable costs to the Government. Reasonable Allocation of Costs, Effort Reporting, Sub-recipient Monitoring, Cost Transfers, Indirect Costs, Cost Sharing Originally Created by Geoff Grant, Partners Health Care

13 Significant Audits & Settlements Johns Hopkins Univ. Effort Certification $2.7 million University of Minnesota Misuse of federal funds $32 million New York University Medical Center Inflated Research Grant Costs $15.5 million Mayo Foundation Mischarging Federal Grants $6.5 million Harvard/BIDMC Costing Issues (Self-Reported) $3.25 million Northwestern University Committed Time/Effort $5 million Univ Alabama, Birmingham Effort Certification & Clinical Research Billing $3.4 million East Carolina Univ Questioned Costs HHS/OIG Audit $2.4 million Univ. of Southern California Questioned Costs HHS/OIG Audit $400,000 Florida International Univ. Effort Certification & Direct Costs $11.5 million Univ. California, San Francisco Animal Care Allegations $92,500 fine Cornell Medical Clinical Research Issues $4.4 million